planning report GLA/2885c/01 30 April 2018 White City Campus South Masterplan in the Borough of Hammersmith & Fulham planning application no. 18/00267/OUT

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008.

The proposal Redevelopment of the site to construct an employment-led mixed use development comprising up to 178,102 sq.m. of office and research and development floorspace, 13,539 sq.m. of flexible commercial, leisure and community use, a 9,290 sq.m. hotel and 373 residential units, with buildings ranging from 2 to 32 storeys, together with supporting highways infrastructure and public realm.

The applicant The applicant is Imperial College London and the architect is Allies and Morrison

Strategic issues summary Principle of development: The development of a new research campus, with supporting commercial, leisure, community, hotel and residential uses is strongly supported and would help to deliver the Mayor’s aspirations for ‘Med City’, the White City OAPF and housing targets. The applicant must provide further details to confirm their strategy for providing SME workspace. Affordable housing: 35% affordable housing (comprising intermediate units prioritised for Imperial College London employees and other key workers) is generally supported as a starting point; however, as the scheme is not eligible for the ‘Fast Track Route’, the applicant must submit a Financial Viability Appraisal and early and late stage review mechanisms should be secured. Should the applicant significantly increase the affordable housing offer, GLA officers may be minded to wave the late stage review. Design and heritage: The design, layout and height of the proposed development is supported and would preserve and enhance the significance of the conservation area and would not harm adjacent heritage assets. Climate change: The proposals fall short of the London Plan and draft London Plan targets for reductions in CO2 emissions. Further information has been requested on specific issues, and any remaining shortfall must be secured by the Council through a Section 106 agreement. Transport: Site access improvements must be legally secured, with the new bridge link and associated access improvements delivered prior to occupation and junction improvements at Wood Lane aligned with Cycle Superhighway 10. Transport modelling must be revised before transport mitigation measures can be agreed with TfL. Cycle and car parking provision must be revised to meet draft London Plan standards. TfL infrastructure protection issues must be addressed by condition.

Recommendation That Hammersmith and Fulham Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 81. However, the resolution of those issues could lead to the application becoming compliant with the London Plan and draft London Plan. Context

1 On 8 March 2018 the Mayor of London received documents from Hammersmith and Fulham Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following categories of the Schedule to the Order 2008:

• 1A “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

• 1B(c) “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings - outside and with a total floorspace of more than 15,000 square metres.”

• 1C(c) “Development which comprises or includes the erection of a building of more than 30 metres high and is outside the City of London.”

3 Once Hammersmith and Fulham Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

6 The 5.68 hectare site is located in White City Opportunity Area and forms part of the wider Imperial College London land holding. It is bounded to the north by Imperial College London’s White City Campus North; to the east by the ; to the west by Wood Lane; and to the south by a residential-led mixed use development site under construction by St James, known as ‘White City Living’.

7 The site comprises vacant industrial buildings and areas of hardstanding within the former Dairy Crest depot site, together with Forest House and Stadium House, which are currently occupied office buildings. The site boundary extends under the A40 and includes provision for a new bridge over the Central Line, together with associated highway improvements at the junction of South Africa Road and Wood Lane. The site boundary is shown below in Figure 1.

8 The site has a Public Transport Access Level (PTAL) rating of 6a, dropping to 5 in a small eastern portion (on a scale of 0 to 6b where 6b represents the highest level of public transport access). White City station is approximately 160 metres from the site and Wood Lane Station is located 450 metres further south. There are five bus routes that can be reached in a short walking distance from the site via this route and Cycle Hire Docking Stations are located on Ariel

page 2 Way and Wood Lane. Currently, the only access to the site for vehicles, pedestrians and cyclists is provided via Depot Road, a narrow private road which leads onto Wood Lane and bridges over the Central Line.

9 The wider area is made up of a mix of land uses and building heights and is undergoing considerable change. White City Campus North is nearing completion on the adjacent site to the north of the Westway Flyover and comprises a number of office and research and development buildings, 608 units of post-graduate student accommodation, and a 35 storey residential tower. To the south of the site, the White City Living and Westfield developments would provide approximately 3,000 homes and approximately 50,000 sq.m of retail floorspace, with buildings ranging in height up to 30 storeys.

Details of the proposal

10 The application seeks planning permission to redevelop the site to construct an employment-led mixed use development comprising up to the following maximum levels of floorspace:

Table 1 – maximum floorspace by land use

Maximum floorspace GEA Use Use Class (sq.m.) % Research and development, office and other business space B1 178,102 74% Retail, cafe, restaurant, bar, community A1 to A5, D1 and/or leisure floorspace and D2 13,539 6% Residential (373 units) C3 41,324 17% Hotel C1 9,290 4% Total 242,255 100%

11 The application also includes a new bridge access over the Central Line, junction and access improvements and provides for the redevelopment of Stadium House. In terms of building heights, the application proposes mixed use office buildings ranging from 6 to 13 storeys, residential buildings of 18 to 32 storeys and an 8 storey hotel.

12 The planning application has been submitted in outline form and includes a development specification and parameters plans document which prescribes the location, layout and land use of the development and tightly defines the three dimensional form of the proposed buildings in terms of minimum and maximum heights, separation and set back distances and areas of public realm. In addition, a design code has been submitted which sets out key design principles and rules for forthcoming reserved matters applications, which would be secured by condition. Following any outline planning permission, reserved matters applications would need to be in compliance with the specifications set out in these documents.

13 The masterplan comprises seven distinct development zones which would enclose a large linear central public space, and are shown below in Figure 1. The development specification document sets out the maximum quantum of overall floorspace being sought in each Development Zone as part of the outline application, which is detailed below:

page 3 Figure 1 – Development Zones and upper floor land uses

Development Zone 1

14 Development Zone 1 comprises two buildings located under the A40 Westway which would be occupied by up to a maximum of 2,161 sq.m. of flexible commercial uses falling within Class A1- A5, B1, D1 and D2 use and would range from 13 to 17 metres in height, subject to TfL asset protection requirements.

Development Zone 2

15 Development Zone 2 comprises a 6 storey mixed use building between 36.5 metres and 46.8 metres in height, which would be occupied by up to 3,602 sq.m. of floorspace, with flexible ground floor commercial, community, education and leisure uses within Class A1-A5, D1 and D2 use and office, research and development and other business uses in B1 use and education uses in D1 use on upper floor levels.

Development Zones 3 and 6

16 Development Zones 3 and 6 comprises mixed use buildings fronting the central open space ranging from 50.65 metres to 70.35 metres in height (approximately 10 to 12 storeys) and would be occupied by up to 160,397 sq.m. of research and development, office and other business uses in B1 use on upper levels and flexible commercial, community, education and leisure uses on the ground floor within Class A1-A5, D1 and D2 use.

page 4 Development Zone 4 and 5

17 Development Zone 4 comprises mixed use hotel and residential buildings ranging from 27.5 metres to 121 metres in height (8 to 32 storeys) and providing up to 32,506 sq.m. of internal floorspace, with flexible active commercial uses within Class A1-A5, D1 and D2 at ground floor. Development Zone 5 comprises mixed use residential buildings ranging in height from 18.5 metres to 72.45 metres (6 to 24 storey), providing a maximum of 24,512 sq.m. of residential and commercial floorspace, with flexible active uses in A1-A5, B1, D1 and D2 use at ground floor level and residential units provided on upper floor levels.

Development Zone 7

18 Development Zone 7 is to the west of the Central Line cutting fronting Wood Lane and comprises the redevelopment of Stadium House to provide a mixed use building between 47.4 metres and 58.5 metres in height, providing up to 19,077 sq.m. of internal floorspace, with flexible active commercial uses in A1-A5, D1 and D2 use on the ground floor level and office and education uses in Class B1 and D1 use above.

Phasing and infrastructure delivery

19 In terms of indicative phasing, the applicant has stated that their expectation is that the proposed development would be brought forwards in line with the following sequencing and timescale, subject to planning permission:

• Phase 1 – years 0 to 6 – would comprise the delivery of the new bridge, highways works to the Wood Lane/ South Africa Road junction, the demolition of Forest House, the construction of buildings along the western and northern side of the site within Development Zones 1, 2 and 3 and associated access and landscaping works, and the providing of a new access route under the A40 Westway to connect to the White City North Campus.

• Phase 2 – years 6 to 12 – would comprise the construction of mixed use residential and hotel buildings within Development Zones 4 and 5.

• Phase 3 – years 12 to 20 – would comprise the disassembly of the temporary office and research and development buildings (see paragraph 20) and their replacement with permanent mixed use office buildings in Development Zone 6.

• Phase 4 – years 20 to 22 – would comprise the redevelopment of Stadium House (which would remain occupied until then). Case history

20 Outline planning permission was secured by the previous landowner of the site, Aviva Investors and Helical Bar plc, for a residential-led mixed use redevelopment comprising a maximum of 1,140 homes (10% affordable, subject to a review mechanism), 26,000 sq.m. of commercial floor space, together with new roads, public space and landscaping and a new bridge over the Central Line tracks prior to occupation (Ref: 2012/02454/OUT; GLA Ref D&P/2885).

21 A pre-application meeting was held on 14 June 2017 with the current landowner Imperial College London to discuss a revised employment-led mixed use masterplan for the site which would provide a new research and innovation district focused on science, medicine and engineering related business activities, alongside housing and other supporting mixed uses. The proposed land- use and design principles were broadly supported by GLA officers at pre-application stage; however, concerns were raised in relation to transport.

page 5

22 On 27 March 2018, Hammersmith & Fulham Council resolved to approve Imperial College London’s detailed planning application for a temporary 10 year permission comprising 25,486 sq.m of flexible office, research and development and laboratory space, with up to 300 sq.m. of commercial space at ground floor level within Development Zone 6 (GLA Reg D&P 2885b). This application is also referable to the Mayor. The planning merits of this application are not considered within this report and will be determined separately on its own merits against all relevant planning policies (refer to planning application Reference: 17/04276/FULL; GLA/2885b/01). Strategic planning issues and relevant policies and guidance

23 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Hammersmith and Fulham’s Local Plan (2018) and the 2016 London Plan (Consolidated with alterations since 2011).

24 The following are relevant material considerations: • The National Planning Policy Framework; • National Planning Practice Guidance; • the Draft London Plan (consultation draft December 2017); which should be taken into account on the basis explained in the NPPF; • the White City Opportunity Area Planning Framework (2013); • Opportunity areas London Plan; • Land use principles London Plan; • Housing London Plan; Affordable Housing and Viability SPG; Housing SPG; Play and Informal Recreation SPG; • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Play and Informal Recreation SPG; • Historic environment London Plan; • Inclusive access London Plan; Accessible London: Achieving an Inclusive Environment SPG; • Climate change London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; • Transport London Plan; the Mayor’s Transport Strategy; Funding: the Use of Planning Obligations and the Mayoral Community Infrastructure Levy SPG. • In addition, on 5 March 2018, the Government published the draft revised National Planning Policy Framework for consultation (until 10 May 2018). This should be taken into account appropriately in accordance with its early stage of preparation.

Principle of development

25 The site is within the White City Opportunity Area, which the London Plan identifies as having capacity to accommodate 10,000 new jobs and a minimum of 6,000 new homes. The draft London Plan sets out an indicative guideline for 2,000 jobs and 7,000 homes, which reflects developments that has been approved or built out. London Plan Policy 2.13 and draft London Plan Policy SD1 require development proposals in opportunity areas to optimise potential residential and employment development capacity, provide a mix of uses and support wider regeneration.

page 6 26 The application site falls within a strategic site allocation ‘White City East’ (WCRA1) within Hammersmith and Fulham’s recently adopted Local Plan (February 2018) and is allocated for mixed use development, including the creation of a major world-class academic and business research campus, led by Imperial College London, alongside housing and supporting retail, leisure and community facilities and open space, linked to improvements in pedestrian and cycle connectivity and public transport capacity. These aspirations are also established in the White City OAPF, which sets out a number of employment objectives including the aim to accommodate a range of large, small and medium sized enterprises (SMEs) and start-up companies engaged in bio-medical and scientific research and development, innovative technology, alongside substantial numbers of new homes and supporting commercial uses.

27 The site is no longer an industrial site for planning purposes, having been identified as a strategic site allocation for employment, academic research, residential, leisure, community and retail uses in Hammersmith & Fulham’s Local Plan and the White City OAPF. Moreover, outline planning permission has been granted for mixed use development. As such, the redevelopment of industrial buildings on site as part of an employment-led mixed use development, including residential and commercial uses is strongly supported in accordance with Policy 4.4 of the London Plan and Policy E4 of the draft London Plan.

28 London Plan Policy 4.10 sets out the need to give strong support clusters of research and innovation and London’s higher education institutions by: ensuring the provision of a wide range of workspaces to support the continued growth of these emerging sectors; meeting the accommodation needs of the capital’s universities; and facilitating collaboration between higher education institutions, businesses and other agencies. It recognises, in particular, the need to promote the special status of London’s ‘Med City’ – a growing cluster of medical and life sciences research and development uses and associated health infrastructure facilities which are located around Euston Road, Whitechapel and White City. These aspirations are also set out in the Mayor’s draft Economic Development Strategy and Policy E8 of the draft London Plan which provides strong support for clusters of specialist economic activity, including life sciences research and development associated with London’s ‘MedCity’, as well as other specialist innovative sectors and encourages the provision of suitable workspace. Paragraph 6.8.3 of the draft London Plan recognises the important role of Imperial College London’s White City Campus in achieving these objectives.

29 The critical role that London’s universities play in contributing to the capital’s national and global role as a centre for graduate and post-graduate education and research and the important contribution these institutions make in terms of skills, employment and London’s research reputation, helping to attract businesses to the capital is recognised in London Plan Policy 3.18 and Policy S3 of the draft London Plan, which highlights the need to plan effectively for the future growth of London’s universities to meet demand, particularly in areas that are well-connected to public transport.

30 Imperial College London are close to building out the White City Campus North, with all but two plots now either completed or under construction and have confirmed that there is no further space available within their South Kensington campus. White City Campus North includes the largest molecular sciences research building in the UK; an Innovation Hub building providing start-up, incubation and accelerator space for SMEs and graduates; and 608 units of post- graduate student accommodation. In addition, a bio-medical engineering research hub and 35 storey residential tower are under construction. Together, these facilities provide a substantial cluster of medical, life sciences, engineering and technology research uses, linked to Imperial College London’s South Kensington campus and the nearby Hammersmith Hospital.

page 7 31 The proposed development would provide an employment-led mixed use development led by Imperial College London, which aims to provide a new research and innovation district focused on science, medicine, engineering research and other business related uses. This would comprise a series of mixed use office and laboratory buildings with supporting commercial, community and leisure uses at ground floor level. As such, the proposed development would significantly expand the existing cluster of research and development uses in White City and, on this basis, is strongly supported, in accordance with London Plan Policy 4.10 and Policy E8 of the draft London Plan.

Existing office and education uses

32 Forest House currently includes a number of small businesses affiliated with Imperial College London and Stadium House has been recently refurbished and is occupied by both Imperial and ‘the Invention Rooms’ - a publicly accessible ‘hackspace’ and ‘makerspace’, which also includes an education/community space, which provides workshops and events a with the local community. In total, these two buildings comprise 4,865 sq.m of floorspace in B1 office, research and development and D1 community use. The design and fabric of these office buildings is not of a high quality and their renewal and modernisation as part of a comprehensive mixed use development would improve the overall quality, flexibility and quantity of the office stock in this location and is encouraged, in accordance with London Plan Policy 4.2 and Policy E1 of the draft London Plan. Moreover, the provision of the meanwhile use buildings would precede the demolition of Forest House (subject to planning permission being provided) and would provide 25,486 sq.m of flexible office, research and development and laboratory floorspace space suitable for SMEs, thereby ensuring the provision of suitable replacement workspace, in accordance with Policy E2 of the draft London Plan. Stadium House would not be demolished until the final phase of the development (years 20-22).

SME workspace provision

33 Whilst the approach taken by Imperial College London in providing suitable start-up and SME workspace within specific sectors is recognised, as well as the characteristics of the temporary planning application mentioned above, the applicant must provide further details setting out its strategy for providing permanent workspace that would be suitable for start-up and SMEs and should set out how this space would be managed and provided at a range of rent levels, taking into account the need for lower cost and affordable workspace within the target sectors, in accordance with Policy E1, E2 and E3 of the draft London Plan. GLA officers would welcome further discussions with the applicant to understand what arrangements will be in place to provide scope to incorporate existing businesses at Forest House and Stadium House within the proposed development.

Increasing housing supply

34 The London Plan sets Hammersmith and Fulham a target of 1,031 homes a year, which is increased significantly to 1,648 homes per year in the draft London Plan. To achieve housing targets, London Plan Policy 3.3 and Policy H1 of the draft London Plan emphasise the need to optimise housing delivery on suitable brownfield sites such as this, which are within opportunity areas and have good accessibility to public transport. As such, the proposed provision of 373 residential units (36% of the Council’s current London Plan annual housing target), including 35% affordable housing, is strongly supported in accordance with London Plan Policies 3.3 and 2.13 and Policy H1 and SD1 of the draft London Plan. Whilst the level of housing being proposed is lower than the 1,140 residential units secured by the previous outline planning consent (10% affordable), this is reflective of the site having now been purchased by Imperial College London and their aspiration to bring forward an employment led mixed use scheme,

page 8 which is strongly supported and, on balance, the reduction in potential housing delivery on this site does not give rise to any strategic planning concerns.

Town centre uses

35 Whilst the application proposes a substantial quantum of town centre use (up to a maximum of 200,931 sq.m.) approximately 350 metres from the boundary of the Shepherd’s Bush Metropolitan Town Centre, the overall quantum of floorspace is in accordance with the Development Plan and does not give rise to strategic planning concerns. As such, GLA officers are satisfied that a sequential and impact assessment is not required, in line with paragraph 26 of the NPPF, London Plan Policy 4.7 and Policy SD8 of the draft London Plan.

36 The site is identified as a preferred location for large-scale new office developments in the Local Plan and Local Plan Policy E3 states that planning permission will be granted for new visitor accommodation within the White City Opportunity Area, subject to this facility being well located in relation to public transport (which would be satisfied in this location). The provision of hotel uses in this location is also supported in the White City OAPF, London Plan Policy 4.5 and Policy E10 of the draft London Plan and would contribute to meeting the London Plan targets for additional hotel rooms. Moreover, GLA officers consider that hotel uses would be complementary to the proposed research campus, thereby supporting the successful delivery of the wider masterplan.

37 The Local Plan site allocation (WCRA1) anticipates the provision of small-scale retail uses to support the proposed scale of employment and residential activities on site, which is supported in accordance with London Plan Policy 4.3 and Policy E1 of the draft London Plan. Notwithstanding this, the Council must ensure that the overall scale of retail floorspace provision is appropriately capped by setting out a maximum overall quantum of retail floorspace provision for the site and considering use of maximum size thresholds for individual retail units.

Principle of development – conclusion

38 Overall, the principle of the redevelopment of the site to provide an employment-led mixed use development, including housing would support the Mayor’s objective to promote the development of the emerging cluster of specialist research and development activities in White City and would contribute significantly to meeting housing targets. The proposal would be supported by a necessary scale of supporting commercial, leisure, education and hotel uses, as anticipated in the Local Plan and White City OAPF. As such, the principle of the proposed development is strongly supported, in accordance with London Plan Policies 2.13, 3.3, 4.1, 4.2, 4.3, 4.5, 4.7, 4.10 and Policies SD1, SD8, E1, E8, E10 and H1 of the draft London Plan.

Housing

39 The applicant’s proposed housing mix is set out below:

Table 2 – proposed housing mix

Unit type No. of units % 1 bedroom 1 person 26 7% 1 bedroom 2 person 131 35% 2 bedroom 164 44% 3 bedroom 52 14% Total 373 100%

page 9 Affordable housing and viability

40 London Plan Policies 3.11 and 3.12 and draft London Plan Policy H5 seek to maximise the delivery of affordable housing, with the Mayor setting a strategic target of 50%. Policy H6 of the draft London Plan identifies a minimum threshold of 35% affordable housing (by habitable room). Applications that meet or exceed the relevant threshold level of affordable housing without public subsidy, providing an appropriate tenure split, and which meet other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor can follow the ‘Fast Track Route’ set out in the draft London Plan and the Affordable Housing & Viability SPG. This means that they are not required to submit a viability assessment or be subject to a late stage viability review. To follow the fast track route applicants must have sought grant to increase the level of affordable housing beyond 35%, taking into account the Mayor’s strategic 50% target.

41 The applicant has stated that their aspiration is to follow the ‘Fast Track Route’ and have confirmed that 35% of the proposed residential units on site will be affordable, as set out below in Table 3. Imperial’s intention is that that all of the proposed affordable units would comprise intermediate housing (although the split between intermediate rent and shared ownership has not yet been confirmed) and the units would be prioritised for Imperial College London and Imperial College NHS Healthcare Trust employees, and other specified key workers, including staff at the following organisations: the NHS; the local education authority (Hammersmith & Fulham); Metropolitan Police and British Transport Police; London Fire Brigade; London Ambulance Service; ; and .

Table 3 – proposed affordable housing provision

Tenure Habitable room % by hab room Units % by unit Private 651 65% 242 65% Affordable 351 35% 131 35% Total 1,002 100% 373 100%

42 The applicant states that priority should be given to Imperial College London employees because a lack of suitable affordable homes constitutes a major barrier to attracting and retaining research staff, when in competition with education institutions in other locations. Imperial also suggest that an increased provision of intermediate affordable housing is needed locally to create a more mixed and inclusive community, as ward level census data demonstrates that 55% of all homes are in social rented tenure.

43 In view of the particular characteristics of the proposed research campus development and its role in supporting the Mayor’s wider economic objectives for ‘Med City’ and the cluster of research related activities at White City, there is no in principle objection to the applicant’s affordable housing offer comprising wholly intermediate housing, or its intention to prioritise affordable housing provision for employees at Imperial College London, Imperial College NHS Healthcare Trust and other key workers.

44 The overall affordable housing offer of 35% is generally supported as a starting point; however, noting that a policy compliant tenure mix is not proposed, the application is not currently eligible for the ‘Fast Track’ approach, as a policy compliant tenure mix is not proposed. Therefore, the application must follow the ‘Viability Tested Route’ and a Financial Viability Appraisal (FVA) must be submitted in a standardised format which will be rigorously assessed by GLA officers in conjunction with Hammersmith & Fulham Council to ensure that the maximum level of affordable housing is being delivered. An early and late stage review mechanism should also be secured within any Section 106 agreement, in accordance with Policy H6 of the draft

page 10 London Plan and the Mayor’s Affordable Housing & Viability SPG. Notwithstanding the above and taking into account the unique nature of the proposal and the synergies between the proposed housing and the research campus, GLA officers may be minded to wave the requirement for a late stage review should the applicant significantly improve the overall affordable housing offer in response to the Mayor’s strategic target of 50%.

45 The applicant must also provide further detail to confirm the type and affordability of the proposed intermediate units and these units must be secured robustly by Section 106, in accordance with London Plan Policies 3.9, 3.11, 3.12, the Mayor’s Affordable Housing and Viability SPG, and Policies H7 and H12 of the draft London Plan. Whilst the applicant has not confirmed the mix of intermediate products that would be provided, they have has stated that the units would be set at prices/rents that would be affordable to the following household income levels set out in Table 4, which would ensure provision of intermediate units at a range of incomes levels below the maximum income threshold, in line with paragraph 4.7.9 and the the Mayor’s Affordable Housing and Viability SPG, and this is welcomed. However, this is subject to full interrogation of the applicant’s FVA and full consideration of the provision of intermediate rent at London Living Rent levels where this is proposed.

Table 4 – proposed affordability criteria

% of units households earning less than £30,000 a year 15% households earning less than £45,000 a year 15% households earning up to £60,000 a year 40% households earning up to £90,000 a year 30%

46 The applicant must provide further detail to confirm the type and affordability of the proposed intermediate homes to enable GLA officers to appropriately assess the affordable housing offer, in accordance with the Mayor’s preferred affordable housing tenures, and the affordability criteria set out in Policy H7 of the draft London Plan, the Mayor’s Affordable Housing and Viability SPG, and the London Plan Annual Monitoring Report. The draft London Plan is clear that for intermediate housing products to be considered affordable, the combined rent and service charge should be no greater than 40% of net household income. In addition, intermediate rented products must, as a minimum, be affordable to households on incomes below £60,000 a year, with a higher maximum household income cap of £90,000 a year applied to intermediate shared ownership products.

Housing choice

47 As shown in Table 2, the applicant proposes a mix of unit sizes (including 52 family sized homes) with 42% of the units being either one bed one person or one bed two person dwellings. This is acceptable given the location and high public transport accessibility of the site, the high density nature of the scheme and the type and tenure of the proposed market and intermediate affordable housing units, in accordance with London Plan Policy 3.8 and Policy H12 of the draft London Plan.

Children’s play space

48 Policy 3.6 of the London Plan states that development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. Policy S4 of the draft London Plan states residential developments should incorporate good-quality, accessible play provision for all ages, of at least 10 sq.m per child. Play space provision should normally be provided on-site;

page 11 however, off-site provision may be acceptable where it can be demonstrated that this addresses the needs of the development and can be provided nearby within an accessible and safe walking distances, and in these circumstances contributions to off-site provision must be secured by Section 106.

49 Based on the applicant’s proposed housing mix set out in Table 2 and the GLA’s play space calculator, a child yield of 91 can be expected, resulting in a requirement for 910 sq.m of playspace. The applicant proposes to meet this requirement through a combination of on-site and off-site provision. This would include 760 sq.m. of dedicated play space suitable to 0-5 and 5-11 year old children within private and communal amenity spaces and with additional provision for 12+ year olds, which would be provided either within the public realm; or through off-site provision within 800 metres of the site, which is acceptable and must be secured by the Council within the Section 106 agreement.

Urban design

50 The design principles in chapter seven of the London Plan and chapter 3 of the draft London Plan place expectations on all developments to achieve a high standard of design which responds to local character, enhances the public realm and provides architecture of the highest quality.

Design, layout, movement and public realm

51 The White City OAPF identifies White City East as a grouping of sites where improved connectivity for pedestrians and cyclists and a high quality public realm should be prioritised, helping to better integrate the area with its surroundings. The OAPF sets out a number of principal urban design objectives for the site, which the proposed scheme would help to achieve. This includes the provision of a new decked bridge access over the Central Line and a strategic north- south movement route through the site connecting to Imperial College London’s White City Campus North development under the A40 Westway, which would be marked by a large central public square. To the south, new connections would be formed with the ‘White City Living’ development, helping to knit the proposed development in with the adjacent sites and support the delivery of the overarching movement framework for the regeneration area, as set out in the OAPF.

52 The central public square would be of a significant size, measuring approximately 35 to 55 metres wide and 160 metres in length, and would be appropriately enclosed by mixed use buildings, with flexible active uses provided at ground floor level, including cafes, restaurants, shops, leisure, community and education uses, which would spill out onto this space from under sheltered colonnades. The square would be broken into different sections, with one third of the space featuring large mature trees and lawns and two thirds comprising a paved public plaza with outdoor cafe terraces and a water feature. The space would also be managed and curated by Imperial who intend to provide a range of events to generate activity and sense of place, which is supported.

page 12 53 The new bridge deck access over the Central Line would form the main entrance to the site from Wood Lane leading onto an ‘arrival square’, which aims to provide an inviting gateway to the site for pedestrians and cyclists and would be the only access route for vehicles to the site. Both the central public space and arrival square would be as car-free as possible, with perimeter service roads provided flanking the edges of the site adjacent to the railway to enable deliveries and servicing to be undertaken to the rear and within the basement of buildings. A below-ground vehicle tunnel is also proposed under the arrival square which would ensure vehicles serving Development Zones 4, 5 and 6 would not need to traverse across the public realm. This is strongly supported in accordance with the Mayor’s approach to Healthy Streets and should be secured in the Section 106.

54 Two new buildings would be provided under the A40 Westway to activate this important link to the White City Campus North site which the applicant states would be occupied by commercial and leisure uses that are not noise sensitive. TfL asset protection requirements will have to be addressed within this location. The applicant has stated that further connections to east are not possible due to West line and the West-Cross Route (A3220). TfL have aspirations to facilitate additional east-west pedestrian connections to Kensington and Chelsea from this site, as set out in the White City OAPF, and expects to discuss the feasibility of this with the applicant in more detail.

Building heights and massing

55 The Local Plan site allocation establishes the principle of taller buildings being appropriate in White City East and states that these are likely to be acceptable close to the A40 and A3220, subject to full assessment of their specific impacts. The existing outline planning consent provides for a 32 storey residential tower adjacent to the A40 Westway, which was envisaged to form a gateway with 32 storey tower currently under construction on the White City Campus North site. The proposed development relocates this residential tower to the southern section of the site ,adjacent to the A3220 (Development Zone 5). This aims to provide a better quality of residential accommodation in terms of noise and air quality and provide a clearer transition to the White City Living development to the south in terms of land use and building heights, which is supported by GLA officers. The applicant has assessed the potential for this tower to overshadow the public space and this demonstrates that this space would receive good levels of sunlight throughout the year which would exceed minimum BRE standards and this is considered acceptable by GLA officers. The residential tower would also be appropriately stepped down towards the southern boundary of the site to minimise impacts on the proposed residential development at White City Living.

56 Overall, having reviewed the applicant’s Townscape and Visual Impact Assessment and the height and location of the proposed development, GLA officers are satisfied that the proposed residential tower would not give rise to unacceptable harmful impacts on the surrounding area and would avoid harm to heritage assets or their settings. Moreover, subject to high quality architecture and exemplary building materials being secured and active ground floor uses being provided, GLA officers consider that a proposed tower at this location would enhance the townscape character in this location and is supported as part of a plan-led approach, in accordance with London Plan Policy 7.7 and D8 of the draft London Plan.

57 Policy D2 of the draft London Plan states that development proposals which are more than 30m in height should be subject to additional design scrutiny and review. Whilst an independent design review has not been undertaken at this stage, the applicant has taken part in a detailed iterative pre-application process with the GLA and Hammersmith & Fulham officers regarding the design of the scheme and more detailed scrutiny of the proposed residential tower would follow at reserved matters stage.

page 13 58 The height and massing of buildings fronting the public open space is well-conceived with buildings of a consistent height fronting this space and minimal gaps permitted between these to maintain a sense of enclosure and a pavilion building placed adjacent to the A40 Westway to provide an acoustic buffer. Overall, the layout of movement routes, public spaces and the height and massing of proposed buildings is well-conceived and strongly supported in strategic planning terms. The design code includes appropriate rules to ensure that these essential features would be secured and brought forwards in a consistent manner through separate reserved matters applications to ensure cohesive and coherent design.

Density

59 Draft London Plan Policy D6 requires developments to make the most efficient use of land and to optimise density through a design-led approach to determine site capacity, taking into account site context, public transport access, walking and cycling accessibility and the capacity of surrounding infrastructure. The site is within an opportunity area and has excellent accessibility to public transport. As such, there is no in principle objection to a high density development, subject to appropriate levels of management being secured and baseline standards in residential quality being achieved, as a minimum, together with necessary transport infrastructure being provided prior to occupation. At reserved matters stage, the applicant must confirm the net residential density of the proposed residential component of the scheme and, should this exceed the ranges set out in Policy D6 of the draft London Plan, a management plan must be secured by the Council by condition.

Residential quality

60 London Plan Policy 3.5 and draft London Plan Policy D4 promote quality in new housing provision, with further standards and guidance set out in the Mayor’s Housing SPG (2016). In accordance with this strategic priority, it is essential that residential quality is embraced fully, and baseline standards achieved and exceeded wherever possible, especially for high density residential developments of this nature. Whist residential floorplans and layouts have not been provided at this stage, all of the proposed residential units must meet the minimum space standards set out in the London Plan and draft London Plan and include appropriate provision of private outdoor space (eg balconies), which must be secured by condition. The number of single aspect units must be minimised as far as possible and dual aspects maximised, in accordance with Policy D4 of the Draft London Plan and the Housing SPG.

Inclusive design

61 The applicant has stated that 10% of the residential units will meet Building Regulation M4(3) ‘wheelchair user dwellings’, and the remaining 90% will comply with Building Regulation M4(2) ‘accessible and adaptable dwellings’. This is strongly supported and must be secured by the Council by condition, in accordance with London Plan Policy 3.8 and Policy D5 of the London Plan.

62 The need to provide necessary clearance over the Central Line would result in a change in levels of approximately 3.4 metres from Wood Lane to the central area of the research campus, which the applicant proposes to address through the provision of a wide deck access which would include a series of landscaped slopes to provide step-free access at suitable gradients, with resting places provided, which is acceptable. Whilst pre-existing changes in gradient across the site also present a challenge and descend towards the southern boundary of the site, the proposed final site levels would achieve a gradient of between 1:14 to 1:50 metres, which is also acceptable given these existing constraints. However, given the inadequacy of the existing access to the site, these measures should be legally secured and delivered prior to occupation. As described above, central areas of the public realm within the site would comprise shared pedestrian priority spaces, with vehicle access strictly managed. Provision would be made

page 14 for managed vehicle access around the edge of the central public space which would allow for essential drop-off parking and disabled access. Further disabled parking provision would be provided at basement level.

Heritage

63 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”. In relation to conservation areas, special attention should be paid to the desirability of preserving or enhancing the character of conservation areas when making planning decisions. The NPPF states that when considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation and the more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. London Plan Policy 7.8. and Policy HC1 of the draft London Plan states that development should conserve heritage assets and avoid harm.

64 The site falls within the Wood Lane Conservation Area, which is dominated by the Grade II Listed BBC Television Centre and was originally cast to include the site in order protect the setting of this building, rather than because of any particular architectural or historic interest associated with the existing warehouse and office buildings. A separate conservation area consent has already been granted to demolish these buildings. Having regard to the urban design assessment above, the applicant’s Townscape Visual Impact and Heritage Assessment, and the relevant legal and planning policy requirements, GLA officers are satisfied that the proposed development would preserve and enhance the character and appearance of the Wood Lane Conservation Area and would not harm the setting of the Grade II Listed BBC Television Centre or the Old Oak and Wormbolt Conservation Area, Oxford Gardens Conservation Area, Avondale Conservation Area, and Avondale Park Gardens Conservation Area, which are nearby.

Climate change

65 Based on the energy assessment submitted, an on-site reduction in CO2 emissions of 26% beyond 2013 Building Regulations compliant development is expected on the domestic element of the scheme and 29% on the non-domestic element. This would be achieved through a range of passive design, demand reduction measures (comprising an energy centre and Combined Heat and Power units) and renewable energy technologies (comprising 1,790 sq.m. of photovoltaic panels).

66 As the application falls short of the on-site target set out in Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan, the applicant must consider the scope for additional measures aimed at achieving further carbon reductions during the reserved matters stage. Further information must also be required at reserved matters stage, including an overheating analysis and an assessment of the cooling demand of proposed buildings. Any remaining shortfall in CO2 reductions must be provided through either a cash-in-lieu contribution to the borough’s carbon offset fund and/or off-site and must secured by the City Council through a Section 106 agreement, in accordance with London Plan Policy 5.2 and Policy SI2 of the draft London Plan.

67 The applicant must ensure that all of the Development Zones and uses are connected to the proposed energy centre and must explore the potential for a larger percentage area of roof space being used for photovoltaic panels. Further technical information is also required for

page 15 review at this stage, including a domestic overheating checklist, sample BRUKL files, and evidence of the applicant’s investigations regarding the feasibility for connection to a district heating network.

Flood risk and sustainable drainage

68 A flood risk assessment has been undertaken which demonstrates that the site is located in Flood Zone 1 and, whilst there is generally a ‘very low’ or ‘low’ risk of surface water flooding on most areas of the site, there are areas of ‘medium’ and ‘high risk’, which are located alongside the depot buildings, railway tracks and under the Westway. The applicant’s drainage strategy would achieve a run-off rate of 75 litres per second for a 1 in 100 year storm event. This rate is equivalent to 3 x greenfield run-off rate for the site and represents a reduction of 57% in comparison with the existing situation on site, which meets the minimum expectations set out in GLA guidance. This would be achieved primarily through the provision of a below ground water attenuation tank (1,680 cubic metres) located below the central public space, and would also feature above ground water feature as part of the public realm design, together with tree planting and permeable paving.

69 Whilst this approach is generally acceptable, the potential for above further ground Sustainable Urban Drainage Systems (eg green roofs and additional green infrastructure) must be fully explored in accordance with the drainage hierarchy before the proposed development can be considered compliant with London Plan Policy 5.13 and Policy SI13 of the draft London Plan. The applicant’s Design and Access Statement proposes the use of green and brown roofs and podium terraces, but states that the scope for this type of provision is likely to be limited on office and research and development buildings as these will potentially need to accommodate substantial amounts of plant equipment. Further details must be provided to the Council on this issue at reserved matters stage.

Transport

Transport assessment and public transport capacity

70 Whilst the overall scope and approach taken in the Transport Assessment is acceptable, the analysis of trip generation and model share is not considered robust and under-estimates the number of public transport trips which are expected to be generated by an office-led development of this scale. The Transport Assessment modelling must be revised in discussion with TfL and, once these deficiencies are addressed, the applicant, the Council and TfL must agree an appropriate financial contribution towards public transport capacity improvements to mitigate the identified additional demand, in accordance with London Plan Policy 6.3 and Policy T3 and T4 of the draft London Plan.

Site access and pedestrian and cycle safety

71 Depot Road provides the only existing access route to and within the site for pedestrians, cyclists and vehicles (including construction traffic) and this is a narrow and poorly lit access road which bends sharply on either side of the Central Line bridge. Pedestrian access is only provided on the southern side of this road within a 1 metre wide footway, behind a guardrail. In view of this access constraint and the poor level of service and safety for vulnerable road users, the proposed bridge link and associated access must be legally secured, delivered and open for use prior to occupation. This provision must also be secured via a Grampian Condition. It is of concern that in the current design there is no segregation for cyclists. The proposed north-south pedestrian and cycle access to the White City Campus North development under the A40 Westway must also be

page 16 secured and delivered once the new bridge access has been provided. The timing of the proposed underground vehicle tunnel must be confirmed and should also be secured.

72 As the intended access arrangements and the proposals for pedestrians, cyclists and vehicle circulation within the site are such fundamental parts of the scheme, baseline principles in terms of phasing and delivery should be agreed with TfL and secured, ahead of any planning permission being granted. TfL’s separate agreement as landowner and to protect operational rail and highway infrastructure will be required and must be subject to further discussion, with appropriate conditions applied.

Walking and cycling

73 Cycle Superhighway 10 (CS10) is proposed to run along Wood Lane and, subject to public consultation, it is anticipated that construction would commence on this scheme in 2020/2021 and, therefore, TfL’s involvement is required to ensure that the proposed new junction on Wood Lane, which would serve the development, is coordinated with CS10 in terms of design, phasing and delivery. Given the strategic importance of CS10 to the sustainable delivery of the proposed development, the scheme must make a commensurate financial contribution towards its implementation, in accordance with London Plan Policy 6.3 and 6.9 and Policy T1, T2 and T5 of the draft London Plan.

74 The previous outline planning consent for this site secured funding for a new cycle hire docking station, together with the necessary land. Given that demand for cycle hire is now expected to be higher under the applicant’s proposed employment-led mixed use scheme, this infrastructure must be secured again, with details to be agreed with TfL. The Travel Plan must include free membership of the cycle hire scheme for an initial period to encourage uptake, which must be secured by Section 106 agreement, in accordance with London Plan Policy 6.3, 6.9 and Policy T4 and T5 of the draft London Plan.

Cycle parking

75 A total of 2,152 long stay cycle parking spaces and 316 short stay cycle parking spaces are proposed as part of the development, which would comply with the minimum standards in the London Plan; however, this falls short of the minimum standards in the draft London Plan. The applicant will be expected to increase this to the minimum standards in the draft London Plan and London Cycling Design Standards and these provisions must be secured by condition.

Car parking

76 A maximum of 100 car parking spaces to serve the proposed office and research and development uses, of which at least 5% of these spaces will be for blue badge holders. A total of up to 149 car parking spaces would be provided to serve the residential element of the scheme (0.4 spaces per unit), of which 10% would be for blue badge holders. Whilst the proposed development complies with the maximum standards set out in the current London Plan, a car free development (except disabled parking) is sought in accordance with Policies T6, T6.1 and T6.2 of the draft London Plan in order to support the Mayor’s vision for healthy streets and targets for active and sustainable travel. The applicant has stated that 20% of all car parking spaces would have electrical charging facilities, with passive provision for a further 20% of spaces, which is welcomed and must be secured by condition, together with disabled parking provision. Policy compliant disabled parking must be secured by condition along with a car parking management plan. To support the on-site parking restrictions, measures should also be put in place to prevent overspill parking from the development in the adjacent sites and in the nearby CPZ.

page 17 Travel plan, servicing and construction

77 Planning conditions or other legal mechanisms must be secured in relation to delivering the key transport mitigation measures detailed above, including: servicing, construction logistics and management, highway, tube and rail infrastructure protection and a travel plan, with the latter focused on encouraging the use of active and more sustainable modes of travel and these must be applied to each phase/development zone within the scheme.

Local planning authority’s position

78 Hammersmith and Fulham Council officers are targeting planning committee during either June or July. Legal considerations

79 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

80 There are no financial considerations at this stage. Conclusion

81 London Plan and draft London Plan policies on opportunity areas, offices, new and emerging economic sectors, town centres, housing, heritage, urban design, climate change, flood risk and sustainable drainage and transport are relevant to this application. The application does not comply with the London Plan and Draft London Plan. However, the resolution of the outstanding issues detailed below could lead to the application becoming compliant:

• Principle of development: The development of a new research campus, with supporting commercial, leisure, community, hotel and residential uses is strongly supported and would help to deliver the Mayor’s aspirations for ‘Med City’, the White City OAPF and housing targets. The applicant must provide further details to confirm their strategy for providing SME workspace.

• Affordable housing: 35% affordable housing (comprising intermediate units prioritised for Imperial College London employees and other key workers) is generally supported as a starting point; however, as the scheme is not eligible for the ‘Fast Track Route’, the applicant must submit a Financial Viability Appraisal and early and late stage review mechanisms should be secured. Notwithstanding this, should the applicant significantly increase the affordable housing offer in response to the Mayor’s strategic 50% target, GLA officers may be minded to wave the late stage review. The type and affordability of the intermediate units must be confirmed and secured robustly in the Section 106.

page 18 • Design and heritage: The design, layout and height of the proposed development is supported and would preserve and enhance the significance of the conservation area and would not harm adjacent heritage assets.

• Climate change: The proposals fall short of the London Plan and draft London Plan targets for reductions in CO2 emissions. Further information has been requested on specific issues, and any remaining shortfall must be secured by the Council through a Section 106 agreement.

• Transport: Site access and junction improvements must be delivered to support the proposed development and legally secured, with the new bridge link and associated access delivered prior to occupation and junction improvements at Wood Lane aligned with Cycle Superhighway 10. Transport modelling must be revised before transport mitigation measures can be agreed with TfL. Cycle and car parking provision must be revised to meet draft London Plan standards. TfL infrastructure protection issues must be addressed by condition.

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 0207 983 4271 email [email protected] Katherine Wood, Principal Planner 0207 983 5743 email [email protected] Andrew Russell, Case Officer 020 7983 5785 email [email protected]

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